Bethlehem Steel Site Profile 

Critical Issues and Questions that need to be addressed truthfully 

June 2006 

1. SITE PROFILE & TECHNICAL BASED DOCUMENT 

Bethlehem Steel’s Site Profile was not completed before the Technical 

Based Document (TBD) was approved on March 30, 2003. Please 

explain. 

1.a.) NIOSH was unaware of the existence of the 10” (10-inch) Bar 

Mill building at the time of the TBD approval. Why? 

1.b.) Other buildings were involved, including the Blooming Mill 

(Reference Wayne Range Letter of June 7, 1976.) 

The purpose of the Blooming Mill was to reduce ingots to billets - 

(ingots) referred to in Government Reports of Bethlehem Steel 

Company but not acknowledged by NIOSH. Why? 

1.c.) NIOSH overlooked the 28,000 sq. ft. of unmonitored high 

Uranium concentration area (sub-basement open under the Cooling 

Bed). They also overlooked the Cooling Bed above. A total area of 

56,000 sq. ft. unaccounted for, without any air data at all. Can this be 

explained? 

2. SITE WORKER INVOLVEMENT/CLAIMANTS 

NIOSH never met with site workers until 16 months after Bethlehem Steel’s 

TBD was approved (July 2004). Why? When at other facilities 

compensation was withheld until the site profile was completed. 

3. Four (4) Bethlehem Steel claimants were compensated prior to the TBD 

approval on March 30, 2003. What was their criteria for compensation? 

4. Once Bethlehem Steel’s TBD was approved, NIOSH began denying 

claimants without having a completed site profile. Please explain. 

1
 
5. Four (4) government-owned facility claimants were compensated without 

a Site Profile, TBD, or Dose Reconstruction prior to Bethlehem Steel’s TBD 

approval. Why should Bethlehem Steel claimants be treated differently? 

6. 1949-1950 No records exist at all. How can NIOSH say that 

“nothing went on” when Bethlehem Steel had contracts to do 

experimental work?

 AT(30-1) -1279 and AT(30-1)-1156. The technical information 

resulting from that work was of a classified nature. And the government 

admits destroying all documentation for that period. NIOSH had no 

knowledge of what went on in 1949 to 1951. Can this be explained in 

detail? 

7. SURROGATE INFORMATION 

Surrogate information used by NIOSH was obtained from Simonds Saw, a 

facility approximately one tenth the size of Bethlehem Steel Company. 

7.a.) Not one procedure at Simonds Saw was comparable to 

Bethlehem Steel’s operation – not even remotely close to allow for a 

comparison. Please explain. 

7.b.) In 1948 at Simonds Saw, many safety procedures were 

implemented while working with Uranium, but those safety 

procedures were never introduced to the experimental process at 

Bethlehem Steel from 1949-1952. Why? Please explain. 

7.c.) Personal monitoring took place at Simonds Saw, but such 

personal monitoring was never considered or conducted at Bethlehem 

Steel. Why? 

7.d.) Simonds Saw site profile was not completed at the time 

Bethlehem Steel’s TBD was approved, but NIOSH was using data 

from Simonds Saw to calculate Bethlehem Steel’s Dose 

Reconstruction and deny claims. 

2
 
8. AIR SAMPLE LOCATION & DATA 

8.a.) After four years of NIOSH stating the “highest area of 

contamination was at the Rollers, we find all the breathing zone 

samples (approximately 9) were taken at the Shear Area 500 feet from 

the Rollers. Please explain. 

8.b.) Many of the original documents are undated, illegible or 

incomplete with no “sample description”. No dates, messy at best. The 

person that took these samples would not testify for NIOSH - Why? 

If NIOSH had the proper records why did they need to talk to Dr. 

Breslin to substantiate the data? Remember this was a Technical 

Document. The air sample data should have been researched 

thoroughly prior to the TBD document approval. Explain please. 

9. GAMMA RAYS 

NIOSH states no Gamma rollings took place at Bethlehem Steel. Refer to 

document HW -22474 Finished Rollings Done at Bethlehem Steel -“ 4 to6 

12 foot long gamma extruded rods”. 

9.a.) If no gamma rollings were done, then why does the 

“Elimination Analysis” refer to “The survey included direct 

measurement of alpha and beta-gamma radiation levels”? 

January 25, 2005 Findings - Item #8 (Beta and Gamma). 

10. ROLLING EXPERIMENTS 

“BBW” - “Best Bar Mill in the World” No other facility in the 

World was doing continuous Uranium rolling. We were Guinea Pigs. 

When doing experimental work you are working with the unknown. The 

government admits (documented) to destroying these records. Please 

explain. 

3
 
 

 

11. PERSONAL PROTECTIVE EQUIPMENT 

No personal protective equipment was issued at Bethlehem Steel such as: 

Glovebox, Masks, Hoods, Film Badges, etc. How can accurate Dose 

Reconstruction be modeled without reliable air data or personal monitoring 

on workers? 

12. LOST URANIUM 

12.a.) Of the approximately 48+ rollings in Bethlehem Steel’s TBD 

only 27.083% of those rollings are actually documented. 

12.b.) Using NIOSH’s figures to calculate the amount of lost 

Uranium: 

Lost Uranium for 48+ rollings at 8 pounds per billet equals 13 tons of 

lost Uranium in 4 years of rollings at Bethlehem Steel. 

Amount of “Lost Uranium”: 13 tons of radioactive material left on the 

site according to NIOSH’s calculations. How did NIOSH account for 

this? 

13. ROUGH ROLLING 

NIOSH states only finished rolling took place at Bethlehem Steel. However, 

the Government documentation verifies that the government purchased 

rough rollers as well as finish rollers for Bethlehem Steel. This error is 

further evidence of the lack of proper (valid) research by NIOSH. 

14. SALT BATH SOAKING TIME REQUIREMENTS & LEAKS
 

4
 
There was a 4-hour loss of time with a salt bath leak. 

Accident: September 22, 1952 

• 303 billets rolled, 9 billets at a time to charge the salt bath 

• 23 minutes average time to soak per charge 

• 759 minutes total time for soaking time 

• 12.5 house needed for soaking only. 

This work cannot be done in a 10-hour working day. It is impossible for this 

work to be done in a 10-hour working day based on the time requirements. 

Please explain this impossibility. How many other inconsistencies and 

invalid claims are in these reports? 

15. MANUAL LABOR 

Far exceeds the rolling process at Simond Saw & Steel 

o Sledge hammer rods into shape 

o Moving rods across salt bath with crowbars 

o Removing cobbles 

o Hand held Geiger counters 

16. GRINDING LOCATION 

No grinding was recognized or incorporated in BSC’s TBD until long 

after claimants were denied. This is a critical error and needs to be 

explained. 

5
 
 

 

17. SKETCH FOR BETHLEHEM’S ROLLING PROCESS 

Submitted into record was a sketch as a description of a 10” rolling mill. 

This sketch was of a completely different rolling process. Explain why the 

wrong sketch was used. On January 25, 2005 at the California meeting 

during SC&A’s presentation, no one challenged the content of the sketch 

where a sheet metal mill was displayed not a rolling mill. Also, it is very 

evident that the 56,000 sq. ft. Cooling Bed area was not depicted and went 

unnoticed by all. 

18. NO CONTAMINATION WHEN ROLLERS STOP 

Finding dated January 25, 2005 - Explain observation #3. 

The statement by NIOSH asserts that when the rollers stopped: “The 

generation of airborne activity would cease.” That observation #3 is invalid. 

NIOSH ignored or refused to address the lack of invalidity of Observation 

#3. Explain the basis for that conclusion. 

NIOSH sent a document of 40 pages, 7 pages were missing. They never 

resolved this specific issue. 

19. BETHLEHEM STEEL COMPANY: A STATE-OF -THE-ART 

FACILITY 

During 1949 - 1952 Bethlehem Steel Company was a state-of-the-art facility 

with no comparable facilities Worldwide. There are no other facilities 

comparable for comparison worldwide. Please explain where NIOSH data 

was obtained. 

6
 
 June 26, 2006 

NIOSH National Institute for Occupational Safety and Health 

Robert A. Taft Laboratories 

4676 Columbia Parkway 

Cincinnati, Ohio 45226-1998 

Issue #14 “Salt Bath Soaking Time” 

Incident: Monday, September 22, 1952 

The air sample data that I requested from ORAU, shows any air data for 

Monday, September 22, 1952. 

On September 22, 1952 our TBD shows that 302 billets were rolled. The 

prior rolling was a week earlier on September 14, 1952 when 303 billets 

were rolled. These were not on consecutive days as the NIOSH Rep. Stated 

at the June 21, 2006 meeting. 

Our point being as follows: 

302 billets were heated in the Salt Bath (divided by 9) 

9 billets were heated at a time (equals 33.6 heats) 

x 23 minutes average heat time per heat 

 equals 771.8 total minutes required for heating only (divided by 60 minutes 

per hour) equals 12.86 Total hours for heating only 

NIOSH allows workers a 10 hr. work day. Note that our approximate 13 hr. 

work day heating time does not allow for any down time such as cobbles, or 

the loading and unloading of the Uranium bars in the Salt Bath. Men moved 

these 1200 degree bars across this bath by hand with steel bars and no 

protection and no breathing zone samples were ever taken. 

We presented this information at our June 21, 2006 meeting. NIOSH 

challenged my figures stating they were incorrect. Could NIOSH explain 

why my math is incorrect? 

There are numerous inconsistencies in this program of which I am prepared 

to discuss with NIOSH. We feel that this is one of the vast amounts of 

incidents that represent how this faulty information was incorporated into 

1
 

our dose reconstruction model time and time again, which certainly makes 

dose reconstruction inaccurate. 

We are only looking for fair and just treatment in this program. 

 Sincerely,

 Edwin Walker

 Bethlehem Steel Action Group 

2